## Facts

- A fire burned Christian E. Porter’s home in Norwich, Connecticut on July 20, 1992.
- Porter was charged with two counts of arson in the first degree under Conn. Gen. Stat. § 53a-111(a)(3) and (4).
- Before trial, Porter retained a polygraph examiner who administered a test indicating Porter’s denials were truthful.
- Porter moved to admit the favorable polygraph results at trial.
- The trial court excluded the polygraph evidence under Connecticut’s categorical rule barring polygraph evidence.
- Porter was convicted; the Appellate Court affirmed.
- The Supreme Court of Connecticut granted review to decide whether to adopt the Daubert standard for scientific evidence and whether to abandon the categorical exclusion of polygraph evidence.

## Issues

1. Whether Connecticut should adopt the Daubert standard as the threshold test for admissibility of scientific evidence.
2. Whether Connecticut should abandon its per se rule excluding polygraph evidence at trial.
3. Whether excluding favorable polygraph evidence without an evidentiary hearing violated the defendant’s federal constitutional right to present a defense.

## Decision

- Connecticut adopted Daubert as the governing threshold standard for admitting scientific evidence.
- Under that approach, the trial court must determine that the proffered scientific evidence is reliable (scientifically valid methodology) and relevant (properly applicable to the facts and helpful to the trier of fact).
- The court retained a per se rule that polygraph evidence is inadmissible in Connecticut trials.
- The court held no evidentiary hearing was required before excluding polygraph results because the evidence remained inadmissible as a matter of law.
- The exclusion did not violate the defendant’s constitutional right to present a defense.
- The judgment affirming Porter’s conviction was affirmed.

## Legal Principles

- Scientific expert evidence is admissible only if it is both reliable and relevant; the trial judge acts as gatekeeper in making that determination.
- Reliability requires that the underlying theory or methodology be scientifically valid; relevance requires that the methodology be properly applied to the case and assist the trier of fact on matters beyond ordinary juror knowledge.
- Even if scientific evidence meets reliability and relevance criteria, it may be excluded when its probative value is outweighed by risks such as unfair prejudice or misleading the jury.
- Polygraph results are categorically inadmissible in Connecticut proceedings governed by the rules of evidence because of disputed accuracy and the risk of undue influence on the jury’s credibility determinations.
- An evidentiary rule grounded in concerns about reliability and prejudice does not, on these facts, unconstitutionally restrict a defendant’s right to present a defense.

## Conclusion

The Supreme Court of Connecticut adopted a Daubert-based reliability-and-relevance test for scientific evidence while maintaining a categorical exclusion of polygraph results, holding that exclusion without a hearing was proper and did not violate the defendant’s right to present a defense.


State v. Porter, 241 Conn. 57, 698 A.2d 739 (Conn. 1997)